Transcription

1 Dancing with Mary Jane: What Family Courts are Making of Medical Marijuana Use in Custody Cases by: Mark Jones 1 Introduction When I first started practicing family law in Georgia, I was utterly amazed at the sheer power wielded by a Superior Court Judge where children are involved. Superior Court Judges pursuant to the injunctive powers granted to them by the Georgia General Assembly under OCGA (e) truly are the gatekeepers to our children s best interests. Under that code section, a Superior Court Judge may issue interlocutory injunctions concerning the custody of children, with or without notice or bond, and upon such terms and conditions as the court may deem just. Id. In this code section, our legislature handed our Superior Court Judges a blank check to issue extraordinary and oftentimes ex parte injunctive relief when a child s best interests are at risk. As the father of three young children, I am still slightly shocked at how much power this code section grants our judges. There is no doubt that these judges are responsible for ensuring our children are protected from threats to their best interests, regardless of whether the threat comes in the form of a prescription pill, a bottle at a liquor store, or a plant prescribed medicinally. With the Georgia House and Senate passing a limited medical marijuana bill, my position is that medical and recreational marijuana use akin to the western states will eventually be in effect in Georgia although the authors of the medical marijuana bill that passed the House and Senate swear that this is not the case. 2 The reason Georgia will eventually adopt a more extensive form of medical or recreational marijuana use is because of the tax revenue associated with it. Medical and recreational marijuana sales as a source of tax revenue, while initially underperforming, appear to be rising as a significant source of tax revenue in states that have legalized it. 3 Medical and recreational marijuana taxes will prove too lucrative for state legislators to ignore. Id. Furthermore, regardless of whether Georgia does or does not pass medical or recreational marijuana laws akin to Colorado or Washington State s, given that everyone has a fundamental right to travel 4 and relocate to such a state, Georgia s family court system will inevitably have to address the issue 1 Mark Jones is a lawyer who practices family law and criminal defense as well as injury law in Columbus, Georgia and Phenix City, Alabama. In 2013, Mark opened his own law firm with nothing but a dream and his small life savings. Mark now has grown his firm to consist of four paralegals, a receptionist, and is currently looking for an associate attorney. Notably, Mark did a local Superbowl ad in the Columbus market in 2015 with a rapper that garnered over 150,000 hits on YouTube. Prior to opening his own law firm, Mark worked as an associate at a personal injury firm for three years. Prior to that, Mark clerked for a Superior Court Judge in Muscogee County. 2 See Ga. S.B. 185 ( ) ( nor is this legislation to be construed as any intent of the General Assembly to be moving in the direction of the legalization of the recreational use of marijuana or other controlled substances. ). 3 See, e.g., Hernandez, Elizabeth Colorado s Record January Marijuana Sales Yield 2.3 Million for Schools, The Denver Post available at: (noting January s [2015] school-designated pot excise tax is more than 10 times the amount in January 2014, when the state first collected the tax on wholesale marijuana transfers. ). 4 See generally, Crandall v. Nevada, 73 U.S. 35 (1868) (noting For all the great purposes for which the Federal government was formed, we are one people, with one common country. We are all citizens of the United States; and, as members of the same community, must have the right to pass and repass through every part of it without interruption, as freely as in our own States. ).

2 of medical or recreational marijuana use in the family law context in the event one parent to a custody dispute decides to move to such a state while the other parent remains in Georgia with the child. Custody cases centered on medical marijuana use in states that permit such use involve a fascinating interplay between a parent s federal constitutional right to raise his/her children as he/she sees fit, 5 a parent s state-based statutory or state constitutional right to use marijuana, 6 and the age-old best interests of the child standard, which ensures that a child is raised in a healthy, wholesome environment. With this in mind, one must address the issue of how medical and/or recreational use of marijuana will impact the largest subset of the legal industry: the family law system. This article examines what family law courts are doing in states that have legalized medical or recreational marijuana in making custody determinations. In examining the appellate decisions, it is fair to say that the following axioms hold true: A family court cannot make a custody determination solely on the basis of a parent s medical or recreational marijuana use in states where such is legal; and Factors a family court judge will consider in making a custody determination include whether: (a) the parent using medical or recreational marijuana uses the drug around the child; (b) the parent using medical or recreational marijuana keeps the drug locked up and out of reach of the child; (c) the parent seeking custody abuses marijuana; (d) the parent s medical condition for which the parent uses medical marijuana; and (e) any other factor associated with the parent s marijuana use that impacts the health and welfare of the child; and The article then concludes by suggesting that family law judges should still employ traditional tools at their disposal in making custody determinations, regardless of the legality of marijuana use in those states that permit it. A Custody Determination Cannot Be Made Solely on the Basis of One Party s Marijuana Use Without a Showing of Specific Harm to the Child s Best Interests by the Parent s Marijuana Use In states where medical or recreational marijuana use is legal, the appellate courts have uniformly held that a family judge cannot make a custody determination solely on the basis of one parent s marijuana use, 7 despite marijuana possession being illegal at the federal level. 8 Even illegal marijuana use, i.e., use without a prescription, in such states is still not enough by itself to warrant a custody denial or modification. 9 5 See generally, Pierce v. Society of Sisters, 268 U.S. 510 (1925). Pierce is generally regarded by constitutional scholars as providing parents with a fundamental right to raise their children as they see fit pursuant to the parent s liberty interest under the 14 th Amendment. 6 For example, a citizen of Colorado has a constitutional right to use marijuana pursuant to the Colorado Constitution, article XVIII, In re Alexis E., 171 Cal.App.4th 438, 90 Cal. Rptr. 3d 44 (Cal. App., 2009) ( mere use of marijuana by a parent will not support a finding of risk to minors. ). 8 See 21 U.S.C. 841, 844; see also Gonzales v. Raich, 545 U.S. 1 (2005) (US Congress may criminalize marijuana use despite state permitting medicinal use). 9 Los Angeles County Dept. of Children and Family Services v. Cornelius, No. LK04159 (Cal App. 2010) (unpublished) ( Several cases indicate that the mere use of marijuana, even illegally, is not alone sufficient ).

3 Indeed, in some states, such as Michigan, the medical marijuana laws actually codify this principle that mere use of marijuana, without more, does not justify a custody modification or finding of child endangerment. 10 The same holds true for Maine, although the legislature there specifically included a reference that a court could consider a party s marijuana use if it impacted the best interests of the child. 11 Nevertheless, even in states that permit marijuana use, the family courts still consider marijuana as a factor in making a custody determination under current case law if the parent s marijuana use constitutes substance abuse or creates a risk of physical or mental harm to the child. 12 There must be some specific nexus, however, between the parent s marijuana use and the best interests of the child. Further, one must also remember that substance abuse in a clinical setting means, a] maladaptive pattern of substance use leading to clinically significant impairment or distress... occurring within a 12-month period. 13 In other words, in order for a parent s legal marijuana use to impact a custody determination, there must be some evidence that the parent s marijuana use endangers the child or is substantially and specifically connected to the parent s parenting skills or judgment. 14 The parent s marijuana use must effect the best interests of the child. 15 Several Common Factors Used by Courts Appear in Cases Where a Parent s Marijuana Use is at Issue Because the best interests of the child standard is traditionally a vague, squishy legal standard, each case involving a child custody determination and a parent s medical marijuana use is heavily fact intensive. However, certain common factors do appear in the appellate decisions in these cases. Generally, these factors center on whether the marijuana use by the parent constitutes substance abuse or somehow impacts the health and welfare of the child. 16 Examples of specificity that warrants denying or modifying custody based on medical marijuana use include: whether the parent uses marijuana around the child; See, e.g., In re Beeler, No (Mich. Ct. App.) (unpublished) (noting, Michigan's Medical Marihuana Act... provides in part, A person shall not be denied custody or visitation of a minor for acting, in accordance with this act, unless the person's behavior is such that it creates an unreasonable danger to the minor that can be clearly articulated and substantiated. ) M.R.S E(3) ( a court may not use a parent's lawful use of medical marijuana as the reason to deny parental rights and responsibilities. ). 12 In re David M., 134 Cal App. 4 th 822 (Cal App. 2005) ( The record on appeal lacks any evidence of a specific, defined risk of harm to either David or A. resulting from mother's or father's mental illness, or mother's [marijuana] abuse. ). 13 Jennifer A. v. Superior Court, 117 Cal App. 4 th 1322, 1346 (Cal App. 2004) (citing American Psychiatric Association, Diagnostic & Statistical Manual of Mental Disorders (4th ed.2000) p. 199). 14 Cornelius, supra note 9 ( There was no testimony linking the mother's marijuana use to her parenting judgment or skills. There was no evidence of a diagnosis by a medical professional or any clinical evaluation and determination that the mother had a substance abuse problem based upon her use of marijuana. ). 15 Daggett v. Sternick, 2105 ME 8 (2015) ( the best interest of the child necessarily involves considering whether a parent's ability to care for his or her child is impaired, including by his or her marijuana use. ). 16 See Dept. of Human Servcs v. Radiske, 144 P.3d 943 (Or. App. 2006) (noting Children have a right to grow up in a wholesome and healthy environment, free from abuse, injury, or neglect ). 17 Cf. Parr v. Lyman, 240 P.3d 509 (Colo. App. 2010) (father objected to family law judge s condition that father refrain from marijuana use while exercising parenting time).

4 the form of marijuana used by the parent; 18 how secure the parent keeps the marijuana stored; 19 the parent s attitudes towards marijuana use; 20 whether the parent exercising custody has a history of substance abuse; 21 whether the paren s friend or known associates use marijuana; 22 and lapses in parental judgment linked to marijuana use. 23 Medical marijuana use by a parent also begs the question of what exactly is the medical issue the parent using medical marijuana is suffering from because a parent s physical health is surely a factor to consider in determining best interests of the child. 24 In sum, factors the courts consider in making a custody determination where a parent uses marijuana legally generally revolve around whether the parent is abusing marijuana or whether the parent s legal marijuana use exposes the child to risk of harm. Suggestions for Family Court Judges In cases where a parent is using marijuana legally, a family court judge should not consider her hands tied. Rather, she should still employ traditional means of monitoring a parent for drug use such as drug tests 25 and drug counseling, 26 depending on the extent of the parent s marijuana use. A drug test for THC metabolites will still show the extent of a parent s marijuana use and drug counseling would be warranted where there is specific evidence of substance abuse or a need for parental education concerning the impact of marijuana use when children are around. A judge absolutely can restrict a parent from using marijuana while in the presence of the child, 27 whether the use is legal or not and may even be able to restrict the parent s marijuana use to a specific form of marijuana 28 to prevent ill effects on the child. Though the appellate courts in states where some form of marijuana use is legal have uniformly rejected a per se custody denial or modification rule simply because a parent uses marijuana, they have also uniformly held that the child s health and well-being is the paramount concern in a custody dispute See, e.g., Riverside County Dept. of Pub. Soc. Servcs v. L.M., E (Cal. App. 2015) (noting father exposed child to second hand marijuana smoke). 19 Daggett, supra note 15 (parent stored voluminous amounts of marijuana in areas where child could access). 20 Cornelius, supra note 9 (father testified that he was not worried about [the child] eating marijuana. ). 21 Id. 22 Los Angeles Cnty. Dep't of Children & Family Servs. v. Anthony O. (In re S.U.) (Cal. App., 2011) (court noted that father no longer associated with friends who used marijuana). 23 Jennifer A. supra note Demski v. Petlick, (Mich. App. 2015) (noting, the mental and physical health of the parties as a factor in relation to a parent s medical marijuana). 25 Jennifer A. supra note 13 (court used drug tests to monitor extent of parent s medical marijuana use). 26 See, e.g., Anthony O. supra note 22 (court ordered drug counseling as part of reunification plan). 27 Parr supra note Cf. State v. Nelson, 195 P.3d 826 (Mont. 2008) (court restricted probationer to pill form of marijuana despite medical marijuana prescription). 29 In re Marriage of Wieldraayer, No I (Wash. App. 12/22/2008) (Wash. App., 2008) ( Merely because Cameron is entitled to use marijuana to improve his medical condition under [the law] does not mean that such use is not detrimental to his young daughters. In the family law setting, the best interests of the child are of paramount importance. ).

5 In short, in custody cases, family court judges should continue to use the tools at their disposal to monitor parents who are using marijuana legally but should be sure to include specific findings of fact in the event of a modification or denial of primary custody where a parent legally uses marijuana. Conclusion Like it or not, family court judges throughout the United States will continue to be confronted with a parent s legal marijuana use in family law cases because more states will continue to pass laws permitting medical or recreational marijuana use. As a general rule, even though marijuana use in any form remains illegal at the federal level, the case law is clear that marijunan use by a parent, without more, is not sufficient to warrant denying a parent custodial rights or modifying custody to a child. Rather a specific nexus between harm to the child s best interests and the parent s marijuana use must be shown. Common factors family courts have used in making custody decisions where a parent uses legal marijuana all center on whether a parent s marijuana use constitutes substance abuse or otherwise harms the child. Regardless of whether a parent s marijuana use is lawful, family court judges should continue to use traditional items in their judicial toolbox to monitor and otherwise regulate a parent s marijuana use in family law cases.

Ruling Guides Parents on Legal Conundrum of Moving a Child. By Mitchell A. Jacobs and David L. Marcus * In its most recent child custody move-away case, the California Supreme Court in In re Marriage of

Filed 7/6/15 L.S. v. Superior Court CA5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified

Filed 6/29/16 In re A.S. CA1/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication

Are Employee Drug Tests Going Up in Smoke? Robert D. Meyers Meghan K. McMahon On January 1, 2014, the nation s first marijuana retail stores opened in Colorado. This landmark event came approximately 14

IN THE INTEREST OF D.C. and K.H., Minor Children, IN THE COURT OF APPEALS OF IOWA No. 14-0318 Filed May 14, 2014 D.R., Mother, Appellant. Appeal from the Iowa District Court for Linn County, Barbara Liesveld,

Protecting Children From Secondhand Smoke When Parents Divorce or Separate 1 June 5, 2003 (Updated February 2011) Exposure to secondhand smoke kills 58,000 people each year. 2 It can be especially dangerous

Filed 11/23/15 G.M. v. Superior Court CA5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified

IN THE SUPREME COURT OF THE STATE OF ARIZONA KRISTINA R. DOBSON, Petitioner, v. THE HONORABLE CRANE MCCLENNEN, JUDGE OF THE SUPERIOR COURT OF THE STATE OF ARIZONA, IN AND FOR THE COUNTY OF MARICOPA, Respondent

IN THE COURT OF APPEALS OF TENNESSEE AT KNOXVILLE May 22, 2006 Session RJS and TLPB v. STATE OF TENNESSEE DEPARTMENT OF CHILDREN S SERVICES, In Re: ETB, a Juvenile Direct Appeal from the Juvenile Court

Filed 6/19/09 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FOURTH APPELLATE DISTRICT DIVISION TWO In re A.S., a Person Coming Under the Juvenile Court Law. M.S., v. Plaintiff

IN THE ARIZONA COURT OF APPEALS DIVISION ONE TRAVIS LANCE DARRAH, Petitioner, v. THE HONORABLE CRANE MCCLENNEN, Judge of the SUPERIOR COURT OF THE STATE OF ARIZONA, in and for the County of MARICOPA, Respondent

Filed 10/9/15; pub. & mod. order 10/27/15 (see end of opn.) IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FOURTH APPELLATE DISTRICT DIVISION THREE In re the Marriage of TERRI E. and GLENN RICHARD DRAKE.

In the Matter of Jane Doe, a minor Child, STATE of Idaho, DEPARTMENT OF HEALTH AND WELFARE, Petitioner- Respondent, v. Jane DOE I, Respondent-Appellant. [Cite as State, Department of Health and Welfare

DISTRICT COURT, CITY & COUNTY OF DENVER, COLORADO 1437 Bannock Street Denver, Colorado 80202 Plaintiff(s): Transitional Medication, LLC v. Defendant(s): City and County of Denver; City of Denver Department

Filed 10/21/15 In re Ts.M. CA2/8 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e(1. 2015 IL App (3d 140968-U Order filed

This opinion will be unpublished and may not be cited except as provided by Minn. Stat. 480A.08, subd. 3 (2012). STATE OF MINNESOTA IN COURT OF APPEALS A12-2155 Marvin Orlando Johnson, petitioner, Appellant,

IN THE COURT OF APPEALS STATE OF ARIZONA DIVISION TWO FILED BY CLERK JAN 31 2013 COURT OF APPEALS DIVISION TWO THE STATE OF ARIZONA, v. SCOTT ALAN COLVIN, Appellant, Appellee. 2 CA-CR 2012-0099 DEPARTMENT

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION No. 04-13-00816-CV IN THE INTEREST OF A.M.L., a Child From the 38th Judicial District Court, Medina County, Texas Trial Court No. 12-11-21526-CV

COLORADO REVISED STATUTES *** This document reflects changes current through all laws passed at the First Regular Session of the Sixty-Ninth General Assembly of the State of Colorado (2013) *** TITLE 18.

-U No. 2-15-0427 Order filed October 15, 2015 NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule

YOUTH DRUG DETOXIFICATION 1 The Youth Drug Detoxification and Stabilization Act being Chapter Y-1.1* of The Statutes of Saskatchewan, 2005 (effective April 1, 2006) as amended by The Statutes of Saskatchewan,

Overview Arizona statutes addressing adoption are in Title 8 of the Arizona Revised Statutes. Federal laws concerning Indian Children also apply to adoption and are contained in the Indian Child Welfare

NOT DESIGNATED FOR PUBLICATION STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT JAC 07-795 STATE IN THE INTEREST OF S.R.W. & F.M.W. ********** APPEAL FROM THE THIRTY-THIRD JUDICIAL DISTRICT COURT PARISH

FIRST DIVISION PHIPPS, C. J., ELLINGTON, P. J., and MCMILLIAN, J. NOTICE: Motions for reconsideration must be physically received in our clerk s office within ten days of the date of decision to be deemed

Pursuant to Ind.Appellate Rule 65(D, this Memorandum Decision shall not be regarded as precedent or cited before any court except for the purpose of establishing the defense of res judicata, collateral

IN THE COURT OF APPEALS OF THE STATE OF IDAHO Docket Nos. 39169/39170 STATE OF IDAHO, Plaintiff-Respondent, v. TESHA JOWANE SUNDAY, Defendant-Appellant. 2013 Unpublished Opinion No. 679 Filed: September

Filed 12/15/98 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FOURTH APPELLATE DISTRICT DIVISION THREE LAURA B., Petitioner, v. THE SUPERIOR COURT OF ORANGE COUNTY, G023979

michael e. hersher Home Schooling in California The recent decision of the California Court of Appeal in the Rachel L. case set off a storm of protest from the California home school community and drew

Alabama 30-3-169.4 30-3-132 Unless there has been a determination that the party objecting to the change of the principal residence of the child has been found to have committed domestic violence or child

Rules and Regulations: A primer on formal rulemaking processes and procedures in Colorado October 2012 George Lyford Page 1 of 9 Rulemaking the formal process of passing, or promulgating regulations is

Case 1:07-cv-00389-MJW-BNB Document 51 Filed 08/21/2008 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 07-cv-00389-MJW-BNB ERNA GANSER, Plaintiff, v. ROBERT

WHAT LANDLORDS NEED TO KNOW ABOUT THE LEGALIZATION OF MARIJUANA (AMENDMENT 64) The election results are final. Colorado along with Washington State became the first two states to legalize the recreational

Filed 11/24/15 P. v. Faccone CA1/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication

Pursuant to Ind.Appellate Rule 65(D, this Memorandum Decision shall not be regarded as precedent or cited before any court except for the purpose of establishing the defense of res judicata, collateral

Filed 9/19/13 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION THREE LAS VEGAS LAND AND DEVELOPMENT COMPANY, LLC et al., Plaintiffs and Appellants,

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3)

IN THE SUPREME COURT OF THE STATE OF KANSAS No. 99,491 KANSAS DEPARTMENT OF REVENUE, Appellant, v. JILL POWELL, Appellee. SYLLABUS BY THE COURT 1. Under the Kansas Act for Judicial Review and Civil Enforcement

Originally published in The Colorado Lawyer, Vol. 20, No. 5, May 1991. THE CIVIL LITIGATOR New Shield Law Prohibits Most Subpoenas to Reporters by Daniel E.D. Friesen and Andrew M. Low A new Colorado law

IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE AT KNOXVILLE Assigned on Briefs July 21, 2015 STATE OF TENNESSEE v. NOAH KEITH TIPTON Appeal from the Circuit Court for Monroe County No. 14165 Andrew M. Freiberg,

2015 IL App (1st) 141310-U FIRST DIVISION October 5, 2015 No. 1-14-1310 NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances

Pursuant to Ind.Appellate Rule 65(D, this Memorandum Decision shall not be regarded as precedent or cited before any court except for the purpose of establishing the defense of res judicata, collateral

WHEN A CHILD MAY HAVE A TORT CLAIM: WHAT S THE CHILD S COURT- APPOINTED ATTORNEY TO DO? The Oregon Child Advocacy Project Professor Leslie J. Harris and Child Advocacy Fellows Colin Love-Geiger and Alyssa

EVIDENTIARY ISSUES SURROUNDING THE USE OF DRUG TEST RESULTS IN CHILD WELFARE CASES AND THE USE OF DRUG TEST IN DEVELOPING TREATMENT PLANS The purpose of Chapter 7 of the Children's Code Section 63-7-10

GROSS, C.J. DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT July Term 2010 DEPARTMENT OF CHILDREN AND FAMILIES, Appellant, v. D.B.D., the father, Appellee. No. 4D09-4862 [August 25, 2010]

FAMILY LAW NEWS & REVIEW LOS ANGELES COUNTY BAR ASSOCIATION FIRST QUARTER 2010 assist in the making of the child custody decision, and further delay in proceedings would have resulted if a new child custody

NOTICE: THIS DECISION DOES NOT CREATE LEGAL PRECEDENT AND MAY NOT BE CITED EXCEPT AS AUTHORIZED BY APPLICABLE RULES. See Ariz. R. Supreme Court 111(c); ARCAP 28(c); Ariz. R. Crim. P. 31.24 IN THE COURT

This article originally appeared in The Colorado Lawyer, Vol. 25, No. 26, June 1996. by Jeffrey R. Pilkington TORT AND INSURANCE LAW REPORTER Informal Discovery Interviews Between Defense Attorneys and

Filed 5/16/13; pub. order 6/12/13 (see end of opn.) IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (El Dorado) ---- STEVE SCHAEFER, Plaintiff and Respondent, C068229 (Super.

: Minnesota Criminal Code - Chapter 609 Overview This chapter provides an overview of Minnesota s Criminal Code, Chapter 609 of Minnesota Statutes, to help you recognize the most common types of criminal

People v. Verce. 11PDJ076, consolidated with 12PDJ028. June 11, 2012. Attorney Regulation. The Presiding Disciplinary Judge suspended Joseph James Verce (Attorney Registration Number 12084), for a period

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e(1. 2015 IL App (3d 121065-U Order filed

5.51 LEGAL MALPRACTICE (Approved 6/79) CHARGE 5.51A Page 1 of 9 A. General Duty Owing An action brought against an attorney alleging negligence in the practice of law is referred to as a malpractice action.

14 Vesey Street New York, NY 10007-2992 (212) 267-6646 www.nycla.org WRITTEN TESTIMONY PRESENTED BY THE NEW YORK COUNTY LAWYERS ASSOCIATION MATRIMONIAL LAW SECTION AT THE PUBLIC HEARING ON NO-FAULT DIVORCE

The Arizona State Hospital The Arizona State Hospital is the only long-term inpatient psychiatric facility in Arizona. Before ordering that you receive treatment at the Arizona State Hospital, the court